Customer identification: Data to be collected in future under the EU AML Regulation

The new EU AML Regulation (in full: Regulation (EU) 2024/1624 of the European Parliament and of the Council on the prevention of the use of the financial system for the purposes of money laundering or terrorist financing) largely replaces national money laundering regulations. For the first time, this creates a directly applicable, standardised European AML set of rules.

This also involves revised specifications for the data to be collected as part of customer identification.

Compared to the previous disclosures under the German Money Laundering Act (GwG), numerous details have changed. Obligated parties must be prepared to adapt their internal processes and systems to the stricter and extended requirements of the EU AML Regulation.

The following two overviews show the main changes between the AMLA and the EU AML Regulation with regard to natural persons and legal entities.

Natural persons - mandatory information in the context of identification

The following overview shows in blue which mandatory information pursuant to Art. 22 para. 1 lit. a) EU AML Regulation is added in comparison to the AMLA (black) for the identification of natural persons:

Identification of natural person AMLA vs EU AML Regulation - Customer identification: Data to be collected in future under the EU AML Regulation - Regpit

Legal entities - mandatory information in the context of identification

The following overview shows in blue which mandatory information pursuant to Art. 22 para. 1 lit. b) EU AML Regulation is added to the identification of legal entities in comparison to the AMLA (black):

Identification of legal entities AMLA vs EU AML Regulation - Customer identification: Data to be collected in future under the EU AML Regulation - Regpit

Consequences for practice and implementation

The EU AML Regulation will apply from 10 July 2027, from which date obliged entities under anti-money laundering law must have integrated the above-mentioned and many other requirements of the EU AML Regulation into their KYC processes. In this context, the draft RTS on customer due diligence (CDD requirements) pursuant to Art. 28 (1) of the EU AML Regulation of the European Banking Authority (EBA) must also be taken into account. This draft RTS further specifies which information obliged entities must collect in future as part of the KYC process.

About the RTS draft